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BRC Clause 3.9.2 V7

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Posted 05 January 2016 - 05:36 AM



I am reviewing our traceability procedures to comply with the V7 of the global standards for Food Safety. 


The clause states "The site shall test the traceability system across the range of product groups to ensure traceability can be determined from raw material including primary packaging to finished product". 


We currently record traceability of all food contact packaging. i.e CPET tray and film over the tray. Is the clause now stating we need to include the carton, which the tray it put into. Packaging that the consumer receives with the product.


Thanks for any advise on this 





Cristina L

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Posted 05 January 2016 - 05:47 AM



For me " primary packaging" is the packaging that comes in direct contact with the food, so the carton is not primary, for your product the tray and film is primary.


All the best,



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Posted 05 January 2016 - 07:01 PM

Hi Martyn,


I'm not entirely sure whether yr ultimate query referred to 3.9.1 or 3.9.2 ? Or both ? (3.9.1 also has the "relevant" packaging "bonus")


Textually BRC seem to (scope) distinguish between “identification” in 3.9.1 and “testing” in 3.9.2. Such a distinction, if any, seems rather illogical IMO.


From the glossary –


Primary packaging - That packaging which constitutes the unit of sale, used and disposed of by the consumer (e.g. bottle, closure and label).


Secondary packaging  - Packaging that is used to collate and transport sales units to the retail environment (e.g. corrugated case)


Assuming glossary is accurate, if the outer carton you refer to is classified as secondary  the answer is apparently No.


However, from a risk assessment POV, primary packaging is also definable as packaging which is potentially in food contact. This could expand the scope as compared to above definition.


From above threads, it is unclear to me how auditors have been interpreting “primary” in the context of 3.9.2.


Also see these 2 related threads which may overall clarify the topic a little –






For BRC6 (where .1 and .2 were very similar to BRC7), BRC offered a "Traceability Introduction" including a sort of model example which, vaguely, "implies" all packaging is potentially relevant, see -




It may all come down to the actual packaging style, ie Primary = ?

Kind Regards,



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